This publication examines the integration of gender diversity policies by competent authorities in the banking sector. It assesses the effectiveness of information collection processes and the follow-up on gender-neutral remuneration policies. Finally, recommendations and best practices are proposed to enhance the supervision and implementation of these policies within credit institutions.
This report, entitled "Peer review on Gender Diversity," was published by the European Banking Authority (EBA) in November 2025. It covers the supervision by competent authorities (CAs) of the implementation of gender diversity policies in credit institutions (CIs) between March 1, 2023, and March 31, 2025. The scope includes six national authorities (Austria, Czech Republic, Germany, Greece, Finland) and the Single Supervisory Mechanism (ECB/SSM), focusing on compliance with European legal requirements (CRD, CRR) and EBA guidelines related to diversity and internal governance.
The report assesses how competent authorities have integrated and supervised legal requirements on gender diversity in credit institutions. Despite legal obligations, a significant share of institutions (27.05%) has not adopted a diversity policy, and only 76.78% of institutions (94.39% of significant institutions) have set targets for the underrepresented gender (p. 7). The peer review examined six key areas: integration of requirements into manuals and supervision planning, data collection, internal benchmarking, monitoring of EBA reports on gender-neutral remuneration, and supervision of internal governance. The majority of authorities have integrated these requirements into their supervisory frameworks. However, three authorities were rated "partially applied" for internal benchmarking, and one authority did not take sufficient measures to follow EBA recommendations on gender-neutral remuneration and internal governance (p. 8). The EBA recommends improving data collection and publication of benchmarking results to enhance sector transparency and comparison between institutions. A follow-up will be conducted in two years to assess the implementation of recommended measures.
The EBA conducts peer reviews to strengthen consistency and effectiveness of supervisory practices in the EU. This review targets diversity policies and the implementation of gender diversity within the management bodies of credit institutions, in accordance with Articles 74, 88, 91 of the CRD, CRR regulation, and EBA guidelines (EBA/GL/2021/05, EBA/GL/2021/06, EBA/GL/2023/08). The selection of the six competent authorities is based on previous benchmarking data, covering countries with low, medium, and high compliance levels. The objective is to assess regulatory compliance, effectiveness of supervisory practices, and convergence among authorities, while remaining within the prudential framework and without evaluating the roles of other national actors (p. 9-11).
Integration of requirements into supervision manuals and guidelines:
- Most authorities have integrated requirements related to diversity policies into their supervision manuals and procedures, notably in SREP and FAP processes (p. 18-26).
- Some authorities (Austria, Finland, ECB) do not directly supervise equal opportunity and non-discrimination aspects, as these areas fall under other national bodies (p. 13-16, 24-25).
- Minimum quotas for representation of the underrepresented gender are set by law or governance codes in some countries (Austria 30%, Germany 30% for listed companies, Greece 25%, Finland 40% for listed companies) (p. 14-16, 20-21).
Supervision and planning:
- All CAs integrate supervision of diversity policies into their planning, via SREP and FAP assessments, with regular monitoring and dialogues with institutions (p. 27-33).
- Thematic reviews have been conducted, notably in Germany and Greece, to verify the presence and implementation of diversity policies (p. 29, 30).
Data collection and sharing:
- Authorities have implemented processes compliant with EBA/GL/2023/08 guidelines to collect, validate, and transmit data on diversity and gender pay gaps (p. 34-37).
- Automated systems with reminders are used, but data quality remains improvable, requiring manual checks and exchanges with institutions (p. 35-36).
Internal benchmarking:
- Three authorities were rated "partially applied" for conducting and using their own benchmarking of diversity policies (p. 8).
Monitoring of EBA reports on gender-neutral remuneration and diversity:
- One authority did not take sufficient measures to follow EBA recommendations on gender-neutral remuneration and diversity, leading to specific follow-up measures (p. 8).
Supervision of internal governance:
- Supervision covers absence of discrimination, equal opportunities, reduction of pay gaps, and improvement of diversity, but intervention powers vary by authority (p. 8, 52-60).
Findings:
- 27.05% of institutions have not adopted a diversity policy (p. 7).
- 76.78% of institutions (94.39% of significant ones) have a policy with a target for the underrepresented gender (p. 7).
- Most CAs have integrated requirements into their supervisory frameworks (p. 8, 23-26).
- Data collection processes are in place and comply with EBA guidelines (p. 34-37).
Assumptions and interpretations:
- Differences in mandates and national legal frameworks explain variations in supervision of equal opportunity and non-discrimination aspects (p. 13-16).
- Difficulty recruiting female candidates in some small institutions may limit diversity (p. 24).
- Lack of power to impose quantitative targets in some countries limits measure effectiveness (p. 23).
Uncertainties:
- The actual impact of diversity policies on governance and institution performance is not assessed in this report.
- The quality of collected data varies and may affect analysis reliability (p. 35-36).
- Follow-up on corrective measures remains to be confirmed at the next review in two years.
The report concludes that supervision of diversity policies is well established but improvements are needed, notably:
- Strengthen supervision of equal opportunity and non-discrimination aspects by expanding mandates or enhancing cooperation with other national authorities (p. 26, 33).
- Formalize and publish expectations regarding gender representation targets to ensure consistent supervision (p. 26).
- Improve collection, validation, and publication of internal benchmarking results to facilitate sector comparison and encourage best practices (p. 8).
- Take targeted corrective measures for authorities not fully applying EBA recommendations, notably on gender-neutral remuneration and internal governance (p. 8).
- Continue follow-up and review in two years to assess implementation of recommended measures (p. 8).
The report also identifies good practices, such as detailed integration of requirements into supervision manuals, use of automated processes for data collection, and conducting targeted thematic reviews.
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